Process to escalate a Suspicious Activity Report STR/SAR to Compliance Officer

Staff will submit a written internal Suspicious Activity Report or Suspicious Transaction Report (SAR/STR) to the Compliance Officer.

After an internal SAR/STR is submitted to the Compliance Officer(CO) ,  and the CO determines whether the SAR/STR should be submitted to the FIU.

 The FIU cannot speculate the criminal offence it must be explicitly stated.

The internal SAR is a version of the FIU’s SAR/STR template, it is usually a form contained in the Compliance Program.

The Compliance Officer relies on the in the internal SAR so the intelligence provided by frontline staff is crucial.Intelligence goes from employee to the Compliance Officer, then Compliance Officer to the Financial Intelligence Unit.

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP is an author and entrepreneur based in Trinidad and Tobago.

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No representations or warranties are made about the suitability, comprehensiveness and or accuracy of the information and other content contained on this channel. It should be noted that legal information and content can become out of date and I give no undertaking to keep this blog up to date. All liability for any loss or damage of any kind which may be suffered as a result of accessing and using the information and or content of this blog is hereby excluded to the full extent permitted by law.

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What happens after a SAR/STR is made in Trinidad

The Financial Intelligence Unit (FIU) receives the SAR/STR and analyses it. If there is a criminal offence the FIU prepares an Intelligence Report (IR) and forwards it to the Fraud Squad or the Financial Investigative Branch (FIB) of the Trinidad and Tobago Police Service (TTPS) or the Anti-Corruption Unit of the TTPS.

An investigation is then launched based on the intelligence contained in the Intelligence Report. The FIU is supposed to “sanitize” the information by removing names of reporting employee and the Compliance Officer.

Fraud Squad, Financial Investigative Branch , or the Anti-Corruption Investigative Branch (ACIB)  will start visiting the premises of the suspect, asking questions, looking for witnesses, providing the DPP with information in order to receive instructions to start preparing charges.

FIU may be asked for additional information such as any other SARs/STRs reported in the past.

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP is an author and entrepreneur based in Trinidad and Tobago.

Order her new eBook now: How to Hustle from Home: 50 Success Secrets
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Disclaimer:
The content herein is only for informational and educational purposes and does not constitute legal advice. Please be advised that no attorney/client relationship is created by the publishing of this content. You should consult with your attorney at law for independent legal advice.

No representations or warranties are made about the suitability, comprehensiveness and or accuracy of the information and other content contained on this channel. It should be noted that legal information and content can become out of date and I give no undertaking to keep this blog up to date. All liability for any loss or damage of any kind which may be suffered as a result of accessing and using the information and or content of this blog is hereby excluded to the full extent permitted by law.

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What does SAR mean?: AML Expert

SAR is an acronym for Suspicious Activity Report.

It is a report that captures details of  an alleged criminal offence committed by a client or customer of a “listed business “.

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In Trinidad and Tobago the following are “listed businesses” and  have a legal obligation to file a SAR with the Financial Intelligence Unit (FIU).

Motor Vehicles Sales;

Real Estate Agents and Companies;

Gaming Houses (Casinos)

Pool Betting;

Jewellrs;

Art Dealers;

Accountants;

Lawyers;

Independent Legal Prpfessionals;

Trust and Company Service Providers

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP, Bar No. SYA2015211, Attorney at Law. The author is the first Online Lawyer based in Trinidad and Tobago. SHE IS A LECTURER AT  THE ARTHUR LOK JACK GLOBAL SCHOOL OF BUSINESS IN TRINIDAD. She has clients in Guyana, St Vincent, Barbados, the British Virgin Islands and North America. She specializes in Corporate Law and Anti-Money Laundering Compliance. She helps clients to start their Online Business Empire.

ANTOINETTE SYDNEY LAW OFFICE: MONTROSE MAIN ROAD CHAGUANAS, TRINIDAD AND TOBAGO

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